Supervisory permanent establishment requires project-wise duration and qualifying construction nexus; offshore supplies and salary reimbursements rema...
Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pr...
Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
Stay of demand - when Pr. CIT has not mechanically required the Petitioners to pay 20% of the total demand, but has used the discretion, and passed a reasoned order, determining the amount payable at around 14% of the total demand - no interference is called for
Stay of demand - when Pr. CIT has not mechanically required the Petitioners to pay 20% of the total demand, but has used the discretion, and passed a reasoned order, determining the amount payable at around 14% of the total demand - no interference is called for
Note: It is a system-generated summary and is for quick reference only.